Honeywell Smethport International Waxes - EPA

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

STATEMENT OF BASIS HONEYWELL FARMERS VALLEY WAX PLANT

45 ROUTE 446

SMETHPORT, PENNSYLVANIA EPA ID NO. PAD046761763

Prepared by Office of Pennsylvania Remediation

Land and Chemicals Division August 2018

Table of Contents

Section 1: Introduction ..................................................................................................................1 Section 2: Facility Background .....................................................................................................2 Section 3: Summary of Environmental Investigations................................................................3 Section 4: Corrective Action Objectives.....................................................................................10 Section 5: Proposed Remedy .......................................................................................................12 Section 6: Evaluation of Proposed Remedy ...............................................................................15 Section 7: Financial Assurance....................................................................................................17 Section 8: Public Participation....................................................................................................18 Section 9: Index to Administrative Record ................................................................................19

List of Acronyms

AOC AR AST bgs BTEX EPA LNAPL MCL PADEP PRCP RCRA RSL SB SHS SPL SSS TI UST VOC

Area of Concern Administrative Record Above-ground Storage Tank below ground surface Benzene, Toluene, Ethylbenzene, Xylenes Environmental Protection Agency Light Non-Aqueous Phase Liquid Maximum Contaminant Level Pennsylvania Department of Environmental Protection Post-Remediation Care Plan Resource Conservation and Recovery Act Regional Screening Level Statement of Basis Statewide Health Standard Separate-Phase Liquid Site-Specific Standard Technical Impracticability Underground Storage Tank Volatile Organic Compound

Section 1: Introduction

The United States Environmental Protection Agency (EPA) has prepared this Statement of Basis (SB) to solicit public comment on its proposed remedy for the Honeywell Farmers Valley Wax facility located in Smethport, Pennsylvania (hereinafter referred to as the Facility). EPA's proposed remedy for the Facility consists of the establishment of a technical impracticability (TI) zone and a long-term surface water monitoring program, in addition to implementing land and groundwater use restrictions. This SB highlights key information relied upon by EPA in proposing its remedy for the Facility.

The Facility is subject to EPA's Corrective Action program under the Solid Waste Disposal Act, as amended, commonly referred to as the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. ?? 6901 et seq. The Corrective Action program requires that facilities subject to certain provisions of RCRA investigate and address releases of hazardous waste and hazardous constituents, usually in the form of soil or groundwater contamination, that have occurred at or from their property. The Commonwealth of Pennsylvania is not authorized for the Corrective Action Program under Section 3006 of RCRA. Therefore, EPA retains primary authority in the Commonwealth for the Corrective Action Program.

EPA is providing a thirty (30) day public comment period on this SB. EPA may modify its proposed remedy based on comments received during this period. EPA will announce its selection of a final remedy for the Facility in a Final Decision and Response to Comments (Final Decision) after the public comment period has ended.

Information on the Corrective Action program as well as a fact sheet for the Facility can be found at . The Administrative Record (AR) for the Facility contains all documents, including data and quality assurance information, on which EPA's proposed remedy is based. See Section 8, Public Participation, below, for information on how you may review the AR.

Statement of Basis Honeywell Farmers Valley Wax Plant

August 2018 Page 1

Section 2: Facility Background

The Facility is located at 45 Route 446, Smethport, Pennsylvania 16749. It occupies approximately 575 acres primarily bounded by undeveloped land, with some farmland and sporadic residential development primarily to the north. For remedial purposes, the Facility has typically been divided into three areas: the Main Plant Area, the Area South of Cole Creek, and the former Coal Ash Disposal Areas. A location map and Facility layout are attached as Figures 1 and 2, respectively.

The Facility has been used for petroleum refining operations since approximately 1923, when the McKean County Refinery Company was formed and owned the Facility. Quaker State Refining Company (Quaker State) purchased the Facility in 1929 and operated it as a refinery and wax manufacturing facility until 1990. In 1998 Quaker State merged with Pennzoil Products to form Pennzoil-Quaker State Company (Pennzoil-Quaker State). In 1990, Quaker State sold the Facility to Petrowax PA, Inc. Petrowax was acquired in 1995 by the Astor Corporation, which operated the Facility until 1997, when Astor was acquired by AlliedSignal Corporation. In 1999, AlliedSignal merged with Honeywell International (Honeywell), which has been the owner of the Facility since 2000. In 2005, International Waxes, Inc. became the operator of the Facility, with Honeywell remaining as the Facility owner. Since 1990, the Facility has been used exclusively to manufacture various grades of wax for both food-grade and commercial applications.

Statement of Basis Honeywell Farmers Valley Wax Plant

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Section 3: Summary of Environmental Investigations

For all environmental investigations conducted at the Facility, groundwater concentrations were screened against federal Maximum Contaminant Levels (MCLs) promulgated pursuant to Section 42 U.S.C. ?? 300f et seq. of the Safe Drinking Water Act and codified at 40 CFR Part 141, or if there was no MCL for a contaminant, EPA Region III Screening Levels (RSL) for tap water for chemicals was used. Soil concentrations were screened against EPA RSLs for industrial soil. For consistency with the AR, Pennsylvania's non-residential Statewide Health Standards (SHS) will be referenced when discussing investigations performed under oversight of the Pennsylvania Department of Environmental Protection (PADEP).

The US Army Corps of Engineers performed an Environmental Indicator Inspection of the Facility in July 2000 and generated a report in October 2001 that outlined the Facility's operational and environmental history, including a history of prior releases that had occurred at the Facility. Eight current and ten former solid waste management units were identified and described during the inspection, as well as two areas of concern, including the accumulation of separate-phase liquid (SPL) floating on the water table beneath much of the Main Plant Area, which was to become a focal point in the environmental investigations of the Facility to follow.

Main Plant Area Environmental investigations of the approximately 60-acre Main Plant Area of the Facility began in the mid-1980s, when several areas were characterized and closed under PADEP oversight. Contamination composed primarily of petroleum constituents including benzene, toluene, ethylbenzene, and xylenes (BTEX) has impacted soil and groundwater beneath the Facility as a result of historical activities and spills or releases.

Early remedial activities undertaken by Quaker State at the Facility included the installation of an impermeable clay barrier wall along Cole Creek prior to 1990 to inhibit the migration of SPL to the Creek, bailing and skimming of SPL in select wells beginning in the mid-1990s, and the activation of a dual-phase recovery system to recover SPL and groundwater in 1995. In 2004, Pennzoil-Quaker State installed an SPL recovery trench upgradient of the existing clay barrier to collect and remove SPL in this area that had begun to seep into Cole Creek. A watertight sheetpile wall was also installed in this area to mitigate SPL impact to the Creek. Subsequent additional remedial activities included the plugging of a leaking pipe and associated soil removal within the former gasoline storage and blending area. Pennzoil-Quaker State also expanded the dual-phase SPL recovery and SPL skimming networks.

Pennzoil-Quaker State submitted a Notice of Intent to Remediate (NIR) to PADEP in August 2004 that proposed to remediate the Facility to the Site-Specific Standard (SSS) under Pennsylvania's Land Recycling and Environmental Remediation Standards Act, commonly referred to as Act 2. Under the SSS provisions, facilities may develop risk-based standards using EPA-based guidance and demonstrating attainment of the standard through sampling and ongoing monitoring.

Pennzoil-Quaker State submitted the Remedial Investigation (RI)/Risk Assessment (RA) for the

Statement of Basis

August 2018

Honeywell Farmers Valley Wax Plant

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Main Plant Area to PADEP in January 2013. Manual bailing, skimming, and dual-phase extraction activities performed from 1994 to 2012 removed approximately 209,725 gallons of SPL from beneath the Main Plant Area, which had reduced the extent of the SPL plume to approximately 15 acres in size ? a decrease from approximately 25 acres in 1994. By 2012, the thickness of SPL had also decreased to less than two feet within most of the Main Plant Area. While the active remediation has reduced the level of contaminants, modeling of the SPL volume, mobility, and recovery rates demonstrated that transmissivity was low across the Main Plant Area, and complete SPL recovery was unlikely.

Out of over 70 grab and composite surface soil samples collected in the Main Plant Area between 2004 and 2012, benzene exceeded its Industrial RSL at one location (22 milligrams per kilogram (mg/kg)); lead exceeded its Industrial RSL at one location (1440 mg/kg); and arsenic exceeded its Industrial RSL at 20 locations (maximum concentration 1010 mg/kg; average concentration among exceedances 119 mg/kg). Out of over 30 subsurface samples from various depths to 10 feet throughout the Main Plant Area, benzene (maximum concentration 151 mg/kg; average concentration of 46 mg/kg among 12 exceedances), ethylbenzene (maximum concentration 340 mg/kg; average concentration of 168 mg/kg among 8 exceedances), and arsenic (two exceedances of 31.7 mg/kg and 41.4 mg/kg) exceeded respective Industrial RSLs.

Multiple sampling events show that deep groundwater (greater than 125 feet below ground surface (bgs)) is not impacted by Facility-related contaminants. Groundwater samples from the shallow (less than 60 feet bgs) and intermediate zones (60 to 125 feet bgs) have been impacted. Contaminants were detected in 45 wells, with exceedances summarized in the following table.

Summary of Exceedances in Groundwater, microgram/liter (ug/L)

Contaminant

# Exceedances Maximum

Average

Benzene

10

8580

3239

Ethylbenzene

5

3150

1752

Toluene

1

1530

1530

1,2,4-

6

12,600

3513

trimethylbenzene

1,3,5-

5

751

529

trimethylbenzene

Methyl tert-butyl 1

30

30

ether

2-

1

1040

1040

methylnaphthalene

Naphthalene

4

297

185

Bis-ethylhexyl

2

418

213.7

phthalate

Arsenic

20

267

78

Cobalt

1

90

90

Iron

20

129,000

59,570

Manganese

26

11,800

3762

MCL (*RSL) 5 700 1000 56*

60*

14*

36*

0.17* 6

10 6* 14,000* 430*

Statement of Basis Honeywell Farmers Valley Wax Plant

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Outside the footprint of the SPL plume, only four wells and one piezometer contained any SHS exceedances for VOCs. BTEX was not detected in eastern or southeastern point-of-compliance wells near Potato Creek and Cole Creek, suggesting that no impacts to surface water are occurring. Groundwater fate and transport modeling predict that groundwater contamination is unlikely to migrate in shallow groundwater in the direction of Potato Creek (to the east) and the eastern portion of Cole Creek.

The RA evaluated five human exposure routes to contamination: outdoor worker exposed to surface soil, surface water, sediment, and groundwater (via volatilization to ambient air); indoor worker exposed via inhalation of volatiles in indoor air from surface soil, groundwater, and SPL; construction worker exposed to surface and subsurface soil and groundwater; teenage trespasser exposed to surface soil and groundwater (via volatilization to ambient air); and recreator exposed to surface water and sediment.

Results from the RA demonstrated that potential risks associated with receptors are negligible since theoretical excess lifetime cancer risks were below 10-4 and non-carcinogenic risks were all less than a hazard index of 1. An ecological risk assessment demonstrated that site-related constituents are not present in sediment, surface soil, or groundwater at concentrations likely to cause unacceptable risk to local flora and fauna. PADEP approved the RI/RA in April 2013.

In February 2014, Pennzoil-Quaker State submitted a Cleanup Plan for the Main Plant Area to PADEP that evaluated remedial alternatives to address SPL remaining beneath the Main Plant Area. The remedial objectives were to prevent SPL migration to Cole Creek and to further reduce potential risk to receptors.

The reduction in size of the SPL plume from 1994 to 2012 as evidenced by stable or decreasing dissolved-phase contaminant concentrations across the Main Plant Area supported the conclusion that the footprint of the SPL plume is stable. The Cleanup Plan evaluated the current SPL volume, mobility, and low aquifer transmissivity to determine if continued recovery efforts were likely to further reduce SPL mass. In 2014 Pennzoil-Quaker State proposed that the interim SPL recovery system be shut down to evaluate the area under static conditions.

The Cleanup Plan proposed both institutional and engineering controls as remedial components. The institutional controls would restrict area land use to non-residential purposes, restrict groundwater use within the Facility property boundary, and limit building expansion and construction in some areas due to potential vapor intrusion impacts. The engineering controls of the existing sheet pile and clay walls would be maintained to prevent potential sheen occurrence on Cole Creek. The Cleanup Plan was approved by PADEP in May 2014, and the interim SPL recovery system was shut down in June 2014 to begin a one-year monitoring-only period to evaluate SPL stability through 1) monitoring for SPL in any wells outside the SPL footprint, 2) measuring SPL thickness trends, and 3) monitoring surface water for sheens.

After a small sheen was discovered in an approximately one-foot gap between a partially submerged oily water separator pipe and the north bank of Cole Creek in March 2015, PADEP was notified and Pennzoil-Quaker State submitted a Cleanup Plan Addendum in April 2015 that summarized the sheen occurrence, described interim control measures, and proposed additional

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August 2018

Honeywell Farmers Valley Wax Plant

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steps to mitigate the sheen and reduce the potential for future sheen occurrence. A wooden and bentonite control barrier was constructed in April 2015 which helped to control the sheen and restricted it to the immediate 18-inch by 12-inch area near Cole Creek Piezometer (CCPZ) 2.

The yearlong monitoring-only period concluded in June 2015, and all monitoring criteria were met except for the sheen occurrence described above on the north bank of Cole Creek (sheen has never entered the active flowing water of Cole Creek since shutdown of the SPL recovery system, but has been contained by the creek bank and the oily water separator pipe wall).

Dissolved-phase sampling results from the monitoring period met the approved stability criteria and groundwater sampling has not continued following completion of the initial one-year monitoring period. However, static groundwater and SPL levels, SPL thickness data, and monitoring for first occurrence of SPL outside the plume's footprint continue to be monitored and reported in quarterly remedial action progress reports. A summary of the results from the final sampling event is provided in the table, below.

April 2015 Main Plant BTEX concentrations in groundwater, ug/L (MCLs in parentheses)

Well

Benzene (5) Toluene (1000) Ethylbenzene (700) Xylenes (10,000)

MW-1 ND [ ................
................

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